Oh yeah, I figured, and that's bullshit, but it still seems funny to me that the example in the article is that they found a building that "appears to have undergone a rehab inside and out".

I don't know how the system is designed but it seems pretty easy to set up a points system where "one coat paint" does not mean you can raise rent, but "replaced oven, replaced pre-1950 windows with double-paned windows, replaced leaky 1974 toilet with modern dual flush, replaced water damaged 1983 drywall, AND added one coat of paint" would qualify as substantial improvement.